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Topic 88 Recent SC Judgments

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HINDU LAW — COMPREHENSIVE NOTES

Topic 88

Recent Supreme Court Judgments — Annual Update (2023–2026)

Miscellaneous & Cross-Cutting Topics

Relevant Sections: Multiple Statutes

Priority: HIGH | Exam Relevance: RJS/DJS/PCS-J

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Recent Supreme Court Judgments on Hindu Law (2023–2026)

This compilation captures the most significant Supreme Court rulings on Hindu Law from 2023 to early 2026. Updated annually for The Legal Bridge.

A. 2023 — Key Judgments

Shilpa Sailesh v. Varun Sreenivasan

(2023) 2 SCC 567 — 5-Judge Constitution Bench

Ratio: SC has inherent power under Article 142 to grant divorce on irretrievable breakdown of marriage. Cooling-off period under S.13B(2) HMA can be waived. Most significant matrimonial law ruling of 2023.

Revanasiddappa v. Mallikarjun (Enlarged Reference)

(2023) SCC OnLine SC 1087 — 3-Judge Bench (CJI Chandrachud)

Ratio: Children of void/voidable marriages have rights in parents’ property (self-acquired + ancestral to extent of parent’s share) but do NOT become coparceners. Settled the law conclusively.

Society for Enlightenment v. Union of India

(2023) SC

Ratio: Stronger enforcement of Prohibition of Child Marriage Act, 2006. Noted that child marriages persist despite prohibition.

B. 2024 — Key Judgments

Tej Bhan v. Ram Kishan

2024 SCC OnLine SC 3661 (December 2024)

Ratio: Referred S.14 HSA interpretation to LARGER BENCH due to 18+ conflicting SC judgments on interplay between S.14(1) and S.14(2). The most significant succession law development in years. PENDING.

Kallakuri Pattabhiramaswamy v. Kallakuri Kamaraju

November 2024

Ratio: Life interest under a Partition Deed without link to pre-existing maintenance right falls under S.14(2) HSA. Restricted estate preserved.

Dolly Rani v. Manish Kumar Chanchal

(2024) SC — Justice Nagarathna

Ratio: A marriage merely registered under HMA without performing essential ceremonies (saptapadi) is NOT a valid Hindu marriage. Registration alone is insufficient.

Sanjana Kumari v. Vijay Kumar

(2024) SC

Ratio: Customary divorce through a deed is possible under S.29(2) HMA, but the custom must be specifically pleaded and proved. Validity must be investigated by a competent civil court.

Mulakala Malleshwara Rao (Stridhan Locus Standi)

(2024) SC

Ratio: Only the woman has locus standi for recovery of her Stridhan. Father cannot file FIR without daughter’s authorisation.

Uttarakhand UCC Act, 2024

Presidential Assent: 13.03.2024

Ratio: First state to enact Uniform Civil Code. Covers marriage, divorce, succession, adoption for all religions. Implemented 27.01.2025.

C. 2025 — Key Judgments

Sukhdev Singh v. Sukhbir Kaur

(2025) SC

Ratio: Spouse of a void marriage (S.11 HMA) is entitled to permanent alimony under S.25 HMA. S.125 CrPC operates on a different field. Calling wife of void marriage ‘illegitimate wife’ or ‘faithful mistress’ violates Art.21.

ABC v. XYZ

2025 INSC 129

Ratio: Maintenance under S.125 CrPC is ‘not a benefit received by wife but a legal and moral duty owed by husband.’ Expansive interpretation for social welfare provisions.

Reena v. Dinesh (Maintenance + Restitution)

2025 INSC 55

Ratio: Restitution decree does NOT ipso facto disentitle wife from maintenance under S.125 CrPC. Ex parte decree for restitution is not binding on criminal court.

SC Appeal on Tribal Women’s Inheritance

December 2024 / reported 2025

Ratio: SC appealed to Parliament to amend HSA to extend benefits to tribal women. Noted exclusion of STs as discriminatory. Not binding but significant moral nudge.

D. 2026 — Key Developments (Till April 2026)

P.K. Lakshmi v. Gopi (Kerala HC)

2026 KER 20646 (March 2026)

Ratio: Life estate granted to Hindu widow under a will enlarges into absolute ownership under S.14(1) HSA, following Tulasamma. Tej Bhan reference does not dilute Tulasamma’s precedential value until conclusively decided.

Gujarat Uniform Civil Code, 2026

March–April 2026

Ratio: Gujarat becomes second state after Uttarakhand to pass UCC Bill. Covers marriage, divorce, succession, live-in relationships for all religions (except STs).

Uttarakhand UCC (Amendment) Ordinance, 2026

January 2026

Ratio: Procedural, administrative, and penal improvements to the UCC Act, 2024. UCC Day observed on 27.01.2026 (first anniversary of implementation).

Quick Revision — Most Important Cases by Theme

Theme

Case

Year

Irretrievable Breakdown

Shilpa Sailesh v. Varun Sreenivasan

2023

Illegitimate Children

Revanasiddappa (Enlarged Reference)

2023

S.14 HSA Larger Bench

Tej Bhan v. Ram Kishan

2024

Marriage Validity

Dolly Rani v. Manish Kumar

2024

Void Marriage Alimony

Sukhdev Singh v. Sukhbir Kaur

2025

Maintenance Duty

ABC v. XYZ

2025

S.14(1) Reaffirmed

P.K. Lakshmi v. Gopi

2026

UCC Implementation

Uttarakhand 2024 + Gujarat 2026

2024–2026

EXAM TIP: For 2026 exams: The top 5 must-cite recent cases are: Shilpa Sailesh (2023 — Art.142 divorce), Revanasiddappa (2023 — illegitimate children), Tej Bhan (2024 — S.14 larger bench), Sukhdev Singh (2025 — void marriage alimony), and P.K. Lakshmi (2026 — S.14(1) reaffirmed).

— End of Topic 88 —

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